Translator hops and frequency changes

[joebtsflk1]

Here's a question about translators...

Say you have a translator that you want to move via minor change apps, and it'll only take two hops to get it to where it needs to go. (and further assume that said translator is NOT moving to a rated market since those moves are frozen right now) The output frequency is currently on for example 100.1 in community A. It currently is getting blasted by a full power 100.1 that went on the air recently.

So, we want to move the 100.1 translator to community B, but there is a 100.3 full power that has a 60 dBu signal that just touches B's city limits. We can engineer it so 100.1 translator at community B will stay out of the 54 dBu interference contour of 100.3.

But with active listeners of 100.3 even beyond 100.3's 54 dBu interference contour, can 100.3 prevent the 100.1 translator at community B from ever getting approved, or will it have to register complaints once it hits the air?

And can the 100.1 translator at community B argue for a freq change beyond 3 channels up or down, since it's being displaced by 100.3? Or would it be argued that 100.1, having moved into B, can't argue for displacement since it moved into the mess in the first place.

 

[TomT]

As you indicate, anything beyond three channels is no-longer a minor change. Could make move #1 & shift several channels, then move # 2 and shift up to 3 more channels. That assumes that will get you far enough to do some good without running into a different interference problem.

As far as 2 moves & a complete frequency change? Suspect you'll need a Washington shyster to look at that one. I know it's been done, but probably after an injection of $$$$ into the system.

 

[LA_Guy]

You also heve the option to move to the two IF channels (10.6 and 10.8 away) as a minor change.

 

[TomT]

But that's down to 89.3 or 89.5. Down there the primary station must be non-commercial.

 

[Kmagrill]

Translators can receive interference, but they cannot cause it. Usually, the FCC only considers complaints from listeners inside of the service contour of the affected station.

It's incredibly hard for a translator to get displaced, if the translator operator knows what they are doing. The affected station has to show listener complaints and those listener complaints cannot be solicited in any way by the affected station, they must be completely spontaneous. Any connection of the listeners to the station, even if they only reponded to a call for listeners to speak up about interference that they might be having, invalidates the listener responses. Chances of your translator, as a first adjacency, resulting in spontaneous listener complaints is very low. In the very rare case that this actually happens, the FCC will usually let the translator make a major change via minor change application on the grounds that displacing the translator is less of a public benefit than breaking a rule and allowing it to make a major change.

 

[bossbill]

Translators can receive interference, but they cannot cause it. Usually, the FCC only considers complaints from listeners inside of the service contour of the affected station.

It's incredibly hard for a translator to get displaced, if the translator operator knows what they are doing. The affected station has to show listener complaints and those listener complaints cannot be solicited in any way by the affected station, they must be completely spontaneous. Any connection of the listeners to the station, even if they only reponded to a call for listeners to speak up about interference that they might be having, invalidates the listener responses. Chances of your translator, as a first adjacency, resulting in spontaneous listener complaints is very low. In the very rare case that this actually happens, the FCC will usually let the translator make a major change via minor change application on the grounds that displacing the translator is less of a public benefit than breaking a rule and allowing it to make a major change.

In one case I am intimately familiar with, an established FM station encouraged listeners, on air and via their website, encouraged listeners to complain to the FCC if they had interference to any stations due to our FM booster. We had to buy expensive replacement car radios in several cases, as well as a few tabletop receivers.

And the regulations do not limit responsibility for mitigating interference problems to within a contour.

 

[Kmagrill]

Did anyone mention to the FCC that these comments had been solicited? Unless the FCC is told about the practice, they will assume the complaints are legitimate.

 

[TomT]

Doing a 180 on this discussion, this is why anyone responsible for a full-power station must be vigilant. Read the "daily digest" daily!

During the translator window the Twin Falls terrors applied for two translators on my adjacents. Both well inside my protected 57 dbu (I have a B-1). One would have bombed into the downtown of the #2 city in my dual city metro, the other was just north of the main shopping district & mall for the region. Had they gotten on, I doubt I would have been able to get rid of them short of a couple of well-placed chops of a machete on the feedlines.

As it turned out, they were proposing to relay a station some 70 miles away (on my first adjacent??--but a moot point)..that carried the same network program as on my station. A nasty letter to the station's G.M. highlighting the relevant language in the network agreement and shortly thereafter a letter comes in from their attorney indicating permission was withdrawn for rebroadcast. One proposal died, the other moved to a 4th adjacent, where it still sits at the Commission.

 

[PTBoardOp94]

A minor change is 200, 400, or 600 kHz, or one of the IF frequencies as TomT mentioned. From 100.1, any frequency between 99.5 and 100.7 would be a minor change. So, the way I read your question, the answer is yes.

 

[ChiefEngineer]

Translators can receive interference, but they cannot cause it. Usually, the FCC only considers complaints from listeners inside of the service contour of the affected station.

It's incredibly hard for a translator to get displaced, if the translator operator knows what they are doing. The affected station has to show listener complaints and those listener complaints cannot be solicited in any way by the affected station, they must be completely spontaneous. Any connection of the listeners to the station, even if they only reponded to a call for listeners to speak up about interference that they might be having, invalidates the listener responses. Chances of your translator, as a first adjacency, resulting in spontaneous listener complaints is very low. In the very rare case that this actually happens, the FCC will usually let the translator make a major change via minor change application on the grounds that displacing the translator is less of a public benefit than breaking a rule and allowing it to make a major change.

A full power station filed a Petition against two translators in Indiana. It seemed the form letters from listeners were very similar. I went to look at their public file. The complaints were with no interference..the applications were being opposed claiming interference from something not on.

The attorney representing the station, Communications attorney Chris Imlay, had provided a letter in which he encouraged the GM to get letters of complaint from his contacts. It was in the file, I got a copy.

I can't believe the SBE uses him given the policy of fairness and truth. I even got copies of letters asking people to complain. Both translators were licensed.

 

[nd2023]

A 106.3 translator was on the air for a week in NYC. But a full power 106.3 in NJ encouraged its listeners to complain to the FCC about interference, and the translator was shut down. It was supposed to translate 106.7-HD2, but even 106.7 isn't in HD now.